Recall
Recalls
are an appropriate alternative method for removing or correcting marketed
consumer products, their labeling, and/or promotional literature that violate
the laws administered by the relevant country’s legislative body. Recalls afford equal consumer protection but
generally are more efficient and timely than formal administrative or civil
actions, especially when the product has been widely distributed. Manufacturers and/or distributors may initiate
a recall at any time to fulfill their responsibility to protect the public
health from products that present a risk of injury or gross deception, or are
otherwise defective. Firms may also initiate a recall following notification of
a problem by regulatory or statuary organization of the specific country or a
state agency.
The
executing a recall plan is not that easy, if you already read the first part of
the How to
Execute a Product Recall I, then this is later part of execution
plan. Otherwise it is recommended to read the first part of the document before
you read this to learn very first basic steps you need to know about it.
3. Isolation
of Warehouse Stocks of Recalled Product
Identify
and clearly mark stock of recalled products located in your warehouse or other
storage facilities. These products should be isolated and segregated from other
stock to prevent distribution.
Information
should be made available to identify each product affected by the recall such
as:
Description;
Style;
Colour;
Brand;
UPC
code;
Lot
number;
Item
number;
Date
of manufacture or date of import.
4. Tracking
of Distributed Products
A
product recall usually involves the following steps, which may differ according
to local laws:
The
manufacturer or dealer must notify the authorities that responsible for the
type of recalled product of the company’s intention to conduct a product
recall.
Consumer
hotlines or other forms of communication channels must be established. The
scope of the recall will provide: which serial numbers or batch numbers etc.
are recalled, and is often specified.
Product
recall announcements are released on the respective government agency’s website
(if applicable), as well as in paid notices in the daily newspapers. In some
cases, heightened publicity will result in news television reports advising of
the recall.
When
a consumer group learns of a recall, it will also establish a notification
process to notify the public by various means.
In
standard cases, the consumer is advised to return the goods, regardless of
condition, to the seller for a full refund or replacement.
Avenues
for possible consumer compensation will vary depending on the specific laws
governing consumer trade protection and the cause of recall.
A
defect could be the result of a manufacturing or production error; or it could
result from the design of, or the materials used in, the product. A defect
could also occur in a product’s contents, construction, finishing, packaging,
warnings, and/or instructions.
Not
all products that present a risk of injury are defective.
5. Determination
of the consumer Action
“Instruct
customers to remove the product from sale immediately. Determine whether the
recalled products will be repaired, replaced, or destroyed. Determine whether
customers will be instructed to return the recalled products to your warehouse
or other location.”
6. Preparation
and Distribution of e Recall Notice to Your Customers
The
company has to be creative in the event of reaching owners of recalled products
and have to motivate them to respond. The following are examples of types of
notice that may be appropriate. This list is meant as a guide only, and is not
all-inclusive. Companies should check for new and innovative methods of notice and
means of communication that become available, such as use of the Internet, the
staff encourages their use.
A
joint news release from CPSC and the company;
Targeted
distribution of the news release;
A
dedicated toll-free number and/or fax number and/or email address for consumers
to call to respond to the recall notice;
Information
on company world wide web sites;
A
video news release to complement the written news release;
A
national news conference and/or television or radio announcements;
Direct
notice to consumers known to have the product -- identified through
registration cards, sales records, catalog orders, or other means;
Notices
to distributors, dealers, sales representatives, retailers, service personnel,
installers, and other persons who may have handled or been involved with the
product;
Purchase
of mailing lists of populations likely to use the product;
Paid
notices via television and/or radio;
Paid
notices in national newspapers and/or magazines to reach targeted users of the
product;
Paid
notices through local or regional media;
Incentives
such as money, gifts, premiums, or coupons to encourage consumers to return the
product;
Point-of-purchase
posters;
Notices
in product catalogs, newsletters, and other marketing materials;
Posters
for display at locations where users are likely to visit, or retail stores
where items are purchased, etc.
The
Compliance staff must review and agree upon each communication that a company
intends to use in a product recall before publication or distribution. It is,
therefore, imperative that companies give compliance staff advance drafts of
all notices or other communications for distribution to the media, customers,
and consumers.
7. Verification
of Effectiveness of the Recall
Follow-up
with your customers to be sure that they have:
Received
the recall notice;
Removed
the products from sale; and
Completed
the recall action as specified in the notice.
8. Notification
of Consumers
There
are many ways to notify consumers, however following are the most generic ways
of doing it.
News releases
Recall
news releases must include the following:
The name and
location of the recalling company
The name of the
product
The number of
products involved
A description of
the hazard
The number of
deaths, injuries, and incidents involving the product
Detailed
description of the product, including model numbers, colors, sizes, and
labeling
A line drawing or
photograph of the product
Major retailers and
where and when the product was sold
Complete
instructions for consumers on how to participate in the recall
Other Forms of
Notice
Other
sources used to communicate a recall can range from news releases and posters,
letters, advertisements, bulletins and newsletters. Each notice must provide sufficient
information and motivation for the reader or listener to identify the product
and to take the action requested. They should be written in the appropriate
language for the intended audience.
Letters
or other communications should be specific and concise.
The
words “Important Safety Notice” or “Safety Recall” should appear at the top of
each notice and cover letter and should also be on the lower left corner of any
mailing envelope.
Notices
to retailers and distributors should explain the reason for the recall,
including the hazard, and must contain all the instructions needed on how to
handle the product inventory, as well as instructions for displaying posters or
notices, providing information to consumers, and disposing of returned
products.
All
letters and other notices to consumers should explain the reason for the
recall; including injury or potential injury provide complete instructions on
what should be done with the recalled items once collected.
9. Decide
What to Do with the Returned Products
All
recalled items must be disposed in a way that will ensure that unsafe products
do not make their way back into the marketplace. Disposal of products must be
carried out in a manner that is in compliance with municipal and provincial
waste disposal requirements. If products are repaired or corrected, verify
compliance with regulatory requirements before they are redistributed. All
repaired or corrected products must be clearly distinguished from the recalled
products.
10. Termination
of a recall
Termination
of the recall may be considered after all reasonable efforts have been made to
remove the affected products from commerce, including reconciliation, recall
effectiveness, and disposition.
A
termination of the recall may be requested by submitting a written request to
the regulatory authorities.
In
addition to an annual verification of the recall plan, the company may conduct
a mock recall annually or whenever there are significant changes to the plan or
personnel. The mock recall must include
the following elements:
Selecting
a product which has reached the consumer market.
Tracing
the product from the raw ingredient (e.g. source) level to the finished product
in the marketplace.
Verifying
communications systems (e.g. contact information, test emails and faxes, etc.)
to outside contacts.
Modifying
the recall plan to correct any problems encountered during the test.
Records
of these mock recalls will be documented and filed appropriately.
Reference:
Recall
Handbook: http://www.cpsc.gov//PageFiles/106141/8002.pdf
Sample
Recall Plan: http://www.cdph.ca.gov/pubsforms/Documents/fdbRIgde23.pdf
Product
Recall Guide:
https://s0.hfdstatic.com/p/losscontrol/files/private/1287778604098.pdf
Regulatory
Procedures Manual: http://www.fda.gov/ICECI/ComplianceManuals/RegulatoryProceduresManual/ucm177304.htm
http://blog.matthews.com.au/index.php/product-recall-withdrawal-7-facts-every-manufacturer-know/
Developing
a Product Recall and Withdrawal Program for Your Organization
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